richmond, virginia 23219

Department of Medical Assistance Services 600 East Broad Street, Suite 1300

Richmond, Virginia 23219

http://www.dmas.virginia.gov

MEDICAID MEMO

TO: All Providers Participating in the Virginia Medicaid and FAMIS Programs

FROM: Karen Kimsey, Director

Department of Medical Assistance Services (DMAS) DATE: 3/19/2020

SUBJECT: Provider Flexibilities Related to COVID-19

This memo sets out the Agency’s initial guidance on the flexibilities available to providers in light

of the public health emergency presented by the COVID-19 virus. These flexibilities include

expanded telehealth coverage, as well as the waiver of certain program requirements, including

specified service authorizations and prescription drug limitations. DMAS is also waiving specific

provider requirements, as set out below. These flexibilities are relevant to the delivery of covered

services related to COVID-19 detection and treatment, as well as maximizing access to care and

minimizing viral spread through community contact.

Providers of services to members enrolled in Medallion 4.0 and Commonwealth Coordinated Care

Plus (CCC Plus) must follow their respective contract requirements with the managed care plan or

PACE provider. All DMAS contracted managed care plans will follow the DMAS COVID-19

delivery requirements. MCOs may, at their discretion, allow additional enhanced delivery

flexibilities within their provider network.

Please note that the policy changes set out in this memo are in effect during the public crisis, as

set out in the Governor’s Emergency Declaration. This is a rapidly emerging situation and the

Agency is moving quickly to address all aspects having an impact on both members and providers.

Additional changes are forthcoming; DMAS is negotiating with its federal partners to authorize

new flexibilities, which the Agency will announce as they are approved. Providers are encouraged

to frequently access the Agency’s website to check the central COVID-19 response page for both

FAQ’s and guidance regarding new flexibilities as they are implemented. For additional questions

about this memo or other COVID-19 related issues, the agency has created a centralized point of

access for submission at http://dmas.virginia.gov/contactforms/#/general

Billing for COVID-19 Testing

Testing is available through the Division of Consolidated Laboratory Services (State Laboratory)

and from other private laboratories. For testing at DCLS, patients must meet certain clinical and

epidemiologic criteria, and testing will be approved by the Virginia Department of Health. Further

information on testing can be found on VDH’s website. VDH approval is not required for testing

at private laboratories.

http://www.dmas.virginia.gov/

http://dmas.virginia.gov/contactforms/#/general

Medicaid Memo: Provider Flexibilities Related to COVID-19

March 19, 2020

VDH-enrolled clinical laboratories and health care facilities may bill DMAS for medically

necessary, clinically appropriate COVID-19 lab tests using HCPCS Code U0001 (CDC testing

laboratories to test patients for SARS-CoV-2, $35.91) and U0002 (non-CDC testing for SARS-

CoV, $51.31) with effective dates of service on or after February 4, 2020. DMAS’ fee-for-service

billing system has been updated to accept the new codes and service authorization is not required.

Laboratories will need to be Clinical Laboratory Improvement Amendments (CLIA) certified.

DMAS is following the Center for Medicare and Medicaid Services (CMS) guidance for these two

services. All Medicaid Managed Care Plans (MCOs) and Medicaid fee for service (FFS) cover

COVID-19 testing.

Billing for COVID-19 Related Services

DMAS covers medically necessary services to treat or alleviate symptoms related to COVID-19.

The CDC has provided Official Coding Guidelines for health care encounters and deaths related

to COVID-19. All Medicaid Managed Care Plans (MCOs) and Medicaid fee for service (FFS)

cover medically necessary services to treat or alleviate symptoms related to COVID-19.

Coverage of Targeted Services Delivered Via Telehealth

In order to maximize access to medically necessary services during the current public health

emergency, DMAS is expanding coverage of telehealth as a method of service delivery. This is an

initial policy memo; the agency is working as quickly as possible to leverage additional needed

flexibilities in this area; for example, in the area of remote patient monitoring. Medicaid MCOs

may offer additional flexibilities.

"Telehealth services" means the use of telecommunications and information technology to provide

access to health assessments, diagnosis, intervention, consultation, supervision, and information

across distance for both medical and behavioral health services. Telehealth services includes the

use of such technologies as interactive and secure medical tablets, remote patient monitoring, and

store-and-forward technologies. When delivering services via telehealth, providers are required to

adhere to the same standards of clinical practice and record keeping that apply to other covered

services.

During the COVID-19 national emergency and effective immediately, the Office of Civil Rights

at the Department of Health and Human Services “will not impose penalties for noncompliance

with the regulatory requirements under the HIPAA Rules against covered health care providers in

connection with the good faith provision of telehealth during the COVID-19 nationwide public

health emergency.” This applies to telehealth provided for any reason and does not have to be

related to diagnosis and treatment of COVID-19. The full notice and related guidance on

acceptable applications can be found here.

DMAS will reimburse for Medicaid-covered services delivered via telehealth where the following

conditions are met:

To the extent feasible under the circumstances, providers must assure the same rights to

confidentiality and security as provided in face-to-face services. Providers must ensure the

patient’s informed consent to the use of telehealth and advise members of any relevant

privacy considerations.

https://www.cdc.gov/nchs/data/icd/ICD-10-CM-Official-Coding-Gudance-Interim-Advice-coronavirus-feb-20-2020.pdf

https://www.hhs.gov/about/news/2020/03/17/ocr-announces-notification-of-enforcement-discretion-for-telehealth-remote-communications-during-the-covid-19.html


March 19, 2020

DMAS is waiving the requirement that services delivered via telehealth (real-time, two-

way communications) must utilize both audio and visual connection. DMAS is allowing

the use of audio connections in addition to audio-visual connections.

DMAS is waiving the requirement that provider staff must be with the patient at the

originating site in order to bill DMAS for the originating site facility fee. These

“telepresenters” shall not be required for payment of the originating site fee. Telehealth in

the home is discussed more fully below, but no originating site fee shall be paid for

telehealth in the home.

Providers shall submit claims for telehealth services using the appropriate CPT or HCPCS

code for the professional service delivered. In some cases, there are existing codes available

for certain specifically telehealth-focused services. In others, such as behavioral health,

please see the service specific section below for guidance. During the initial phase of the

emergency, the Agency will permit providers who have not previously billed for telehealth

delivery to bill for covered services delivered via telehealth (including audio and audio-

visual) using their usual place of service code as the delivery location, but must document

in the member’s record the alternative location used and that the service was delivered via

telehealth.

Providers are asked to update their systems and procedures as soon as possible to enable

the use of modifiers (GT or GQ) or telehealth POS (02) when billing for services delivered

via telehealth. DMAS will require the use of these codes after the initial phase of the

emergency is over. Additional information will be included in a future memo.

Providers using telehealth POS (02) or modifiers for telehealth services covered under the

prior policy shall continue to use the modifier GT (via interactive audio and video

telecommunications system) or GQ (via synchronous telecommunications system), or POS

code (02) when billing for services delivered via telehealth.

Both services delivered via telehealth and billed using telehealth modifiers, and services

delivered via telehealth and billed without modifiers will be reimbursed at the same rate as

the analogous service provided face-to-face.

Providers shall maintain appropriate documentation to support medical necessity for the

service delivery model chosen, as well as to support medical necessity for the ongoing

delivery of the service through that model of care.

Home as Originating Site

During the current emergency, DMAS will allow the home as the originating site. This is

particularly important for members who are quarantined, those who are diagnosed with or

demonstrating symptoms of COVID-19, or those who are at high risk of serious illness from

COVID-19. Clinicians shall use clinical judgment when determining the appropriate use of home

as the originating site. No originating site fee shall be paid for telehealth in the home.

Telehealth in the Delivery of Behavioral Health Services

DMAS will allow for telehealth (including telephonic) delivery of all behavioral health services

with several exceptions. Services that will be allowable via telehealth include:

Care coordination, case management, and peer services

Service needs assessments (including the Comprehensive Needs Assessment and the

IACCT assessment in mental health and the Multidimensional Assessment in ARTS) and

all treatment planning activities


March 19, 2020

Outpatient psychiatric services

Community mental health and rehabilitation services

Addiction Recovery and Treatment Services

The per diem rates for therapeutic group homes, psychiatric residential treatment facilities, and

inpatient psychiatric hospitalization will not be billable through telehealth; however, within these

services, activities including assessments, therapies (individual, group, family), care coordination,

team meetings, and treatment planning are allowable via telehealth.

As stated above in the general guidance and until otherwise notified, behavioral health providers

delivering services via telehealth (including telephonic communications) shall simply bill and

submit a claim as they normally would in their regular practice. The Place of Service (POS) that

the provider usually bills should remain the same and no modifiers shall be necessary in order to

minimize systems errors during this critical time. Providers shall maintain appropriate

documentation to indicate the mode of delivery and to support medical necessity for the ongoing

delivery of the service through that model of care. As noted above in the general guidance,

providers should move to systems changes to allow Place of Service Codes (02) to reflect

telehealth delivery as this will be required at a future date.

Early Intervention Services

Early Intervention (EI) providers are permitted to use telehealth or remote care delivery for all

ongoing services to include developmental services, physical therapy, occupational therapy, and

speech-language pathology to include monitoring of successful program and instructional

implementation, coaching, treatment teaming and service plan development. Assessments for new

cases can be done on a limited basis in person or using synchronous telehealth technologies at the

discretion of the local service provider with the child and families consent.

Requirements for Member Co-payments (Applicable across MCOs and FFS)

This section applies to any out of pocket costs in Medicaid and FAMIS: All member co-pays have

been suspended, effective March 13, 2020. No co-pays will be collected from any Medicaid or

FAMIS member in order to encourage all members to seek needed medical care and treatment.

Pharmacy Benefit Changes in Response to COVID 19 Effectively immediately, the Fee-for-Service and Medicaid managed care health plans will:

1) Suspend all drug co-payments for Medicaid, FAMIS and FAMIS Moms members,

2) Cover a maximum of a 90-day supply for all drugs excluding Schedule II

drugs. In Virginia, Schedule II drugs include most opioids, amphetamines,

methylphenidate, etc. A complete list of Schedule II drugs can be found

at https://law.lis.virginia.gov/vacode/title54.1/chapter34/section54.1-3448/ .

3) Suspend refill “too soon” edits for all drugs prescribed for 34 days or less. Drugs

dispensed for 90 days will be subject to a 75% refill “too-soon” edit. Patients will

only be able to get a subsequent 90 day supply of drugs after 75% of the prescription

has been used (approximately day 68).

4) Federal and State law prohibit the early refilling of Schedule II drugs except in the

case of an emergency. Pharmacists should refer to Virginia Board of Pharmacy's

guidance for emergency fill procedures.

https://law.lis.virginia.gov/vacode/title54.1/chapter34/section54.1-3448/


March 19, 2020

Pharmacists and prescribers must continue to comply with all applicable state and federal laws and

regulations related to the prescribing and dispensing of controlled substances. Pharmacists are

encouraged to review the Virginia Board of Pharmacy’s Emergency Provisions for Pharmacists

During the COVID-19 Declared Emergency for additional guidance.

Waiving Service Authorization Requirements on Select Services

Providers are required to submit for service authorization review any new request for services and

requests for changes in services (such as an increase or decrease).

Please see Attachment B for a full list of services for which service authorization is being extended

or waived.

Please note that DME providers may deliver up to a two (2)-month supply at a time (60 days)

during the response to the COVID-19 pandemic. DME providers are instructed to bill in monthly

increments with the anniversary date (30 days at a time). Providers will be required to keep records

of patient/caregiver contact to determine the appropriate need for supplies during each 60-day

period if it is determined a second 60-day supply period is needed. Providers are also required to

maintain the normal delivery ticket documentation and proof of delivery.

Suspension of Out-of-Network Requirements (Applicable to Medallion and CCC Plus)

DMAS has asked MCOs to relax out-of-network authorization requirements as appropriate and to

pay the Medicaid fee schedule, in order to expedite needed care for members.

Face-to-Face Service Delivery Guidance for All DMAS-Covered Services:

DMAS is issuing the following recommendations to assist agencies, health care organizations, and

providers, and to assure that members continue to receive necessary interventions.

All providers shall limit the amount of face-to-face contacts with members. If a provider,

member, caregiver, and or anyone in home or facility is experiencing symptoms of a

medical illness, all face-to-face contact shall be minimized or avoided.

All face-to-face requirements including assessments, reassessments, and service delivery

are waived for all members residing in the community, with the exception of instances

when there is concern for the member’s health safety and welfare. Face-to-face meetings

shall be replaced with phone calls with members and/or documentation from providers.

Existing face-to-face requirements continue to apply in cases where there is a compelling

concern for the member’s health, safety and welfare based on the professional judgement

of licensed staff.

Waiver Face-to-Face Requirements – CCC Plus Managed Care Program

For CCC Plus members in nursing facilities

o All face-to-face requirements including initial health risk assessments,

reassessments (both scheduled and triggering), interdisciplinary care team

meetings, and care planning meetings are waived. Face-to-face meetings shall be

replaced with phone calls with the member, family/authorized representatives,

nursing facility staff and/or documentation, e.g., copy of most recent minimum data

set or other available member records. Details on how the information was

https://www.dhp.virginia.gov/pharmacy/news/PharmacyCoronavirusInformation3-13-2020.pdf

https://www.dhp.virginia.gov/pharmacy/news/PharmacyCoronavirusInformation3-13-2020.pdf


March 19, 2020

obtained in lieu of the face-to-face meeting must be documented within the

member’s record.

For CCC Plus members residing in the community

o With the exception of instances when there is concern for the member’s health,

safety, and welfare, all face-to-face requirements including health risk assessments,

reassessments (both scheduled and triggering), interdisciplinary care team

meetings, and care planning meetings are waived. Face-to-face meetings shall be

replaced with phone calls with members and/or documentation from

providers. Face-to-face requirements may be waived for all CCC Plus members

residing in the community if the member’s health, safety, and welfare is maintained

by authorized services and information can be received by using an alternate

method in lieu of the face-to-face meeting. Details on how the information was

obtained in lieu of the face-to-face meeting must be documented within the

member’s record.

o Existing face-to-face requirements continue to apply in cases where there is a

compelling concern for the member’s health, safety, and welfare based on the

professional judgement of licensed staff.

Quality Management Reviews (QMRs)

o All QMR reviews will be desk audit only. All needed materials will be requested

from the provider to conduct the review. Providers will be allowed flexibility in

instances where they have limited staff to submit records.

Annual Level of Care Evaluations (LOCERI)

o All face-to-face requirements to conduct the annual level of care evaluations

(LOCERI) are waived. This waiving of face-to-face requirement is for both past

due and currently due level of care evaluations. For CCC Plus Waiver members

who have had a face-to-face assessment (initial or reassessment) between October

1, 2019 and March 12, 2020, the information from this assessment may be used to

submit LOCERI data in lieu of the face-to-face meeting to complete and submit the

annual level of care evaluation.

Documentation

o Providers shall document in their records the member’s verbal consent,

authorization, and confirmation of participation. The provider shall obtain written

signatures within 45 days after the end of the emergency.

Programs of All-Inclusive Care for the Elderly (PACE) All PACE providers must follow infection control requirements per 42 CFR 460.74, including

implementing infection control plans for each PACE site and for each participant’s

residence. PACE providers should monitor the CDC website and CMS Emergency Preparedness

and Response Operations for the latest guidance and resources.

PACE should follow CDC guidelines for preventing the spread of COVID-19 among participants

and staff (https://www.cdc.gov/coronavirus/2019-ncov/healthcare-facilities/index.html);

however PACE sites are reminded that they are responsible for continuing to provide all required

Medicare and Medicaid covered services including serving participants in their home as well as

taking precautions to prevent the spread of COVID-19. Should there be instances where a PACE

provider needs to implement strategies that do not fully comply with CMS PACE program

https://www.cdc.gov/coronavirus/2019-ncov/healthcare-facilities/index.html


March 19, 2020

requirements in order to provide services to participants, CMS will take those situations into

consideration when conducting monitoring or oversight activities. All PACE sites must document

the rationale for any change in procedures.

PACE sites may use remote technology (telehealth options) as appropriate for participant

assessments, care planning, monitoring, community and other activities that would normally be

provided as a face to face service. CMS will provide PACE sites with notification when alternate

processes should be discontinued.

CCC Plus Waiver

Face-to-face visits:

o For CCC Plus Waiver members, face-to-face Agency RN and Services Facilitation

(SF) visit requirements are waived with the exception of instances when there is

concern for the member’s health, safety, and welfare. This includes agency-directed

RN supervisory visits and SF routine and reassessment visits. Face-to-face

meetings shall be replaced with phone calls or virtual communication (telehealth)

with members and documentation by providers. Visits to initiate services must

be conducted face-to-face in order to ensure adequate service plan

development.

Documentation

o Required DMAS forms shall be used to document the interaction during these

phone calls. Documentation of visits conducted through telehealth must meet the

standards required for face-to-face visits.

o Providers shall document in their records the member’s verbal consent,

authorization, and confirmation of participation. The provider shall obtain written

signatures within 45 days after the end of the emergency.

o Providers shall use existing procedure codes when billing for telehealth visits.

CCC Plus Waiver Service Authorization Extension

o To ensure continuity of care for members, service authorizations for certain CCC

Plus waiver services will be extended. All personal care, respite, private duty

nursing (PDN), and Personal Emergency Response Systems (PERS) service

authorizations with end dates between March 12, 2020 and May 31, 2020 will be

extended by two months. Providers may still submit service authorization requests

during this time period. PDN providers shall continue to be responsible for

obtaining MD orders for services.

Developmental Disability Waivers

Face-to-Face visits:

Face-to-face visits by Support Coordinators

o Requirements for face-to-face visits by support coordinators will be suspended until

the end of the emergency. In the interim, it is expected that Support Coordinators

will conduct telephonic check-ins and request the same updates as would be gained

during a face-to-face visits regarding, health, safety and satisfaction with services.

o For all of these “visits”, providers shall document a reference to COVID-19 so that

future auditors will be reminded of these allowances made during this time frame.


March 19, 2020

QMR visits

o QMR on-site visits will be suspended until the end of the emergency. In the interim,

QMR will conduct desk audits.

NCI survey visits

o NCI Survey visits have been suspended for the next 30 days and will be re-

evaluated at that time.

Telehealth support: Telehealth is generally provided through electronic video chat that is

HIPAA compliant; if video is not available, the SIS, VIDES, annual plan meetings, and

case management visits may be completed telephonically during the emergency.

o DMAS and DBHDS support the completion of annual plan meetings, case

management visits, the VIDES and the SIS via telehealth or telephone until the end

of the emergency.

Telehealth/telephonic support for Therapeutic Consultation will be accepted for those

activities within Therapeutic Consultation that do not require direct intervention by the

behaviorist.

Signatures:

Support Coordinators, including those private entities contracted with a CSB, can certify

that signatures normally required for consent, authorization, and confirmation of

participation, were verified verbally by the case manager with written consent gained

within 45 days after the end of the emergency.

o Documentation should include the name of the person who gave verbal consent, the

date verbal consent was given, what was consented to, as well as alternatives to

what was discussed.

The services facilitator can certify that signatures normally required for agreement,

consent, and authorization for consumer-directed services have been verified verbally by

the service facilitator/case manager with written consent gained within 45 days after the

end of the emergency.

o Documentation should include the name of the person who gave verbal consent, the

date verbal consent was given, what was consented to, as well as alternatives to

what was discussed.

Slots:

No slots will be rescinded or lost during the emergency. DMAS will begin reviewing

Retain Slot Requests once the emergency has ceased and the normal reviews will be

continued from the point in the individual’s process prior to the emergency.

Service Authorization:

Service Authorizations may be retroactively approved for up to 10 calendar days until the

end of the emergency.

Service authorization will prioritize authorizations for In-home Supports, Personal

Assistance, Companion, Group Day, and Crisis services to meet the need during the state

of emergency.

Provider Operations:

A provider cannot provide a service for which they do not have a license or provider

participation agreement.

As long as staff are deemed competent according to the DSP competency standards and

this is documented, training can be expedited.


March 19, 2020

Group Homes and Community Engagement/Day Support

Service Authorizations

Service authorizations will be retroactively approved for up to 10 days until May 1, 2020.

This will be re-evaluated at the end of April to determine if there is a continuing need.

Service authorization will prioritize authorizations for in-home, personal care, companion,

group day, and crisis services to meet the need during the state of emergency.

Electronic Visit Verification (EVV)

EVV requirements remain in effect for agency and consumer directed personal care, respite, and

companion services. In order to ensure prompt and proper payment for services provided to

members during the emergency declaration, DMAS will continue paying claims regardless of the

status of EVV data on the provider's claims until June 30, 2020. This applies to services provided

through fee for service, Commonwealth Coordinated Care Plus (CCC Plus) and Medallion 4.0

managed care plans.

Behavioral Health Services (Applicable across MCOs and FFS)

DMAS will schedule a weekly call with provider associations, MCOs, DBHDS, and invited

stakeholders during the emergency period to provide ongoing updates and receive feedback on

system functioning.

Provider qualifications, licensure requirements, and the structure of the services shall remain

intact. That is, QMHPs, Supervisees, and Residents must remain working under the direction of

an LMHP and BCBA®/BCaBA® must provide supervision to unlicensed staff (i.e. technicians).

Within the ARTS program, CSAC and CSAC-Supervisees must remain working under the

direction of licensed providers authorized by the Board of Counseling. Provider Types allowed to

bill for Medicaid services will remain the same regardless of the delivery method (face to face vs.

telehealth). Providers would continue to utilize the current service and billing National Provider

Identifier (NPI) numbers as they are now regardless of the mode of delivery of care and should

proceed with efforts to include Place of Service (02) Codes to indicate telehealth delivery as these

will be required at a future date.

For any services without specific guidance below:

Face-to-face services shall not be required, but documentation shall justify the rationale for

the service through a different model of care.

Providers shall maintain appropriate documentation if the plan to provide or continue care

deviates from the normal protocol or plan of care.

Current service authorization requirements remain the same.

Specific Service Considerations & Limitations

Therapeutic Day Treatment (TDT), Intensive In-Home Services (IIH), Mental Health Skill-

Building, Behavioral Therapy, Intensive Community Treatment and Psychosocial

Rehabilitation.

o Service delivery may be provided outside of the school setting, office setting, or

clinic setting for the next 60 days.

o Face-to-face services shall not be required, but documentation shall justify the

rationale for the service through a different model of care.


March 19, 2020

o Providers shall maintain appropriate documentation if the plan to provide or

continue care deviates from the normal protocol or plan of care.

o For youth participating in both TDT and IIH, TDT should not be used in the home

as this would be a duplication of services.

o These services shall not be provided to a group of individuals at the same time and

location (with the exception of family members/kinship in the same location) so as

to promote containment of COVID-19 infection.

o For new services, a prior authorization request is required to verify medical

necessity and appropriateness of the service delivery model.

o The prior authorization request for new services will be used to track which

members are continuing to receive these services, assess the appropriateness of the

services being delivered via different modes of treatment, and to determine if this

is an appropriate service to meet the member's needs.

o If the provider is only providing services through telephonic communications, the

provider shall bill a maximum of 1 unit per member per day, regardless of the

amount of time of the phone call(s).

o As the situation evolves regarding COVID-19, DMAS will re-evaluate the need for

prior authorization of services.

Day Treatment/Partial Hospitalization Programs for Adults

o Face-to-face services shall not be required for reimbursement of the services, but

documentation shall justify the rationale for the service through a different model

of care.



o If providers are unable to provide the minimum amount of services required for the

reimbursement of PHP/IOP, providers may bill behavioral therapy, assessment, and

evaluation codes.

o Providers will not be required to discharge members from the service if the provider

is billing outpatient services rather than PHP or IOP codes.

Psychiatric Inpatient Hospitalizations

o The requirement for prior authorization remains in place.

o Therapy, assessments, case management, team meetings, and treatment planning

may occur via telehealth.

IACCT Assessment, Psychiatric Residential Treatment Facility, and Therapeutic Group

Homes

o The requirement for prior authorization remains in place.

o IACCT Assessments may occur via telehealth or telephone communication.

o IACCT Assessments may be completed by out-of- network providers, but these

individuals must be an independent evaluator separate from the residential facility.

o Therapy, assessments, case management, care coordination, team meetings, and

treatment planning may occur via telehealth.

Psychiatric Inpatient and Residential Levels of Care

o For members in residential levels of care (including therapeutic group homes),

medical necessity for continuation of care may be waived if the individual is unable

to transition to lower levels of care due to COVID-19 and quarantines.


March 19, 2020

Addiction and Recovery Treatment Services (ARTS)

ASAM 2.1 and 2.5 Intensive Outpatient and Partial Hospitalization Programs

o Managed Care Organizations will allow up to 14 days after the start of a new service

or after the expiration of an existing authorization for a service authorization

request to be submitted from the provider to the MCO.





o If providers are unable to provide the minimum amount of services required for the

reimbursement of PHP/IOP, providers may bill psychotherapy, assessment, and

evaluation codes.

o Providers will not be required to discharge members from the service if the provider

is billing outpatient services rather than PHP or IOP codes.

ASAM Levels 3.1 and Above





o Therapy, assessments, case management, care coordination, team meetings, and

treatment planning can occur via telehealth or telephonic consults.



o For members in ASAM Level 3.1 and above, medical necessity for continuation of

care may be waived if the individual is unable to transition to lower levels of care

due to COVID-19 and quarantines.

Opioid Treatment Programs (OTP) and Preferred Office Based Opioid Treatment (OBOT)

Services

Individuals with Opioid Use Disorder (OUD) may have high-risk co-morbidities such as chronic

obstructive pulmonary disease (COPD), cirrhosis, or HIV that may increase the risk of severe

disease related to COVID-19. In light of the potential risk of exposure to COVID-19, as well as

barriers to accessing treatment due to illness, quarantine, and risk of serious illness, we ask

providers and staff to exercise clinical judgment and to prioritize the continuation of members’

medication for treatment of OUD.

Recommendations for Reducing Transmission

Please follow the guidance issued by the Department of Behavioral Health and Developmental

Services (DBHDS), the Centers for Disease Control (www.cdc.gov/COVID19) as well as the

Substance Abuse and Mental Health Services Administration (SAMHSA) and the Virginia

Department of Health.

Back-Up Staff

Preferred OBOTs, OTPs, in-network buprenorphine waivered practitioners, and behavioral health

clinicians shall be prepared in the case of staff illness, including making arrangements for back-


March 19, 2020

up prescribers and behavioral health clinicians. DMAS recommends making arrangements in

advance and ensuring in-network back-up providers are available for each Medicaid MCO or

Magellan of Virginia for fee-for-service member. If an in-network provider is not available for a

member, providers shall contact MCO Network Relations staff.

Counseling and Other Requirements

During the Governor’s State of Emergency, DMAS is allowing the counseling component of

Medication Assisted Treatment (MAT) to be provided via telehealth or telephone communication.

If an OBOT or OTP member is unable to participate in counseling services due to COVID-19,

DMAS will not penalize the OBOT or OTP provider for the missed services.

The provider must have emergency procedures in place to address the needs of any member in a

psychiatric crisis. The provider should also ensure that the member continues to have access to

medications to treat OUD, as well as care coordination activities as appropriate. OBOT and OTP

providers may continue to bill for care coordination that is provided telephonically and in the

absence of counseling services, if necessary and appropriate.

Home as Originating Site for Counseling Services

DMAS will additionally allow a member’s home to serve as the originating site for members. This

is particularly important for those who are quarantined, are diagnosed with and/or demonstrating

symptoms of COVID-19, and/or are at high risk of serious illness from COVID-19. Clinicians

shall use clinical judgment when determining the appropriate use of home as the originating site.

The originating site fee will not be available.

Face-to-Face Contact Requirements

Face-to-face contact requirements are waived for care coordinators, counselors, and peer recovery

support specialists within OBOT or OTP. Staff members may use telehealth, including telephonic

communication, and should use the same billing codes. Any type of contact with the member shall

be documented, including the method of contact (face-to-face, telehealth, telephonic.)

Urine Drug Screens

Providers should use clinical judgment when requiring urine drug screens to minimize clinic and

member exposure to COVID-19. DMAS will not penalize OBOTs or OTP’s for missed urine drug

screens during the public health emergency.

Billing for Telehealth Services

Services provided via telehealth or telephonically shall be billed using the currently approved CPT

and HCPCS codes allowed under the ARTS reimbursement structure. Documentation shall

include the mode of service delivery.

Providing Medication for Members with OUD

Guidance on Use of Telehealth for Members and Providers Affected by COVID-19

Ryan Haight Act of 2008

Under the Ryan Haight Act of 2008, general requirements are that the prescribing practitioner shall

have conducted at least one in-person medical evaluation of the patient before prescribing a

controlled substance (including buprenorphine and buprenorphine/naloxone) for treatment of


March 19, 2020

addiction. However, during the federal Health and Human Services (HHS) Public Health

Emergency, the Drug Enforcement Agency (DEA) has lifted the requirements under the Ryan

Haight Act of 2008 for prescribing practitioner to have conducted at least one in-person medical

evaluation of the patient before prescribing a controlled substance scheduled II – V, including

buprenorphine and buprenorphine/naloxone for treatment of addiction.

For as long as the federal HHS designation of a public health emergency remains in effect, DEA-

registered practitioners may issue prescriptions for controlled substances to patients for whom they

have not conducted an in-person medical evaluation, provided all of the following conditions are

met:

The prescription is issued for a legitimate medical purpose by a practitioner acting

in the usual course of his/her professional practice.

The telemedicine communication is conducted using an audio-visual, real-time,

two-way interactive communication system.

The practitioner is acting in accordance with applicable Federal and State law.

Provided the practitioner satisfies the above requirements, the practitioner may

issue the prescription using any of the methods of prescribing currently available

and in the manner set forth in the DEA regulations. Thus, the practitioner may

issue a prescription either electronically (for schedules II-V) or by calling in an

emergency schedule II prescription to the pharmacy, or by calling in a schedule

III-V prescription to the pharmacy

(https://www.deadiversion.usdoj.gov/coronavirus.html).

Home Delivery of Medications

There is nothing under federal law that prohibits delivery of medications from occurring, although

resources to offer this level of service may vary by program. OTPs shall contact the State Opioid

Treatment Authority (SOTA) for information on how to attain approval for take-home dosing.

Naloxone

Providers are advised to write prescriptions for naloxone for members in case of interruptions in

community-based distribution.

Preferred OBOT Prescription Management

During the Governor’s State of Emergency, DMAS asks Preferred OBOTS to consider giving

individuals who are deemed ‘clinically stable’ longer prescription lengths of buprenorphine-

containing products, as permitted by the Virginia Board of Pharmacy. ‘Clinically stable’ should

be determined by the prescribing provider’s clinical judgment and care team. DMAS encourages

providers to consider a minimum two-week supply of buprenorphine-containing products, and

telehealth or telephonic follow up when clinically appropriate to lessen an individual’s risk of

coming into contact with persons who may be carrying the virus.

Providers should review proper prescription storage for the safety and well-being of members.

Sublocade and Vivitrol

If a member is receiving subcutaneous buprenorphine (Sublocade) and cannot attend a clinic,

providers can transition the member to sublingual buprenorphine (Suboxone) without additional


March 19, 2020

in-person examinations. Similarly, members receiving intramuscular naltrexone (Vivitrol) may

be transitioned to oral naltrexone without an additional examination."

Billing Medicaid for Telehealth Services for Prescribing Medications

Services provided via telehealth or telephone shall be billed using the currently approved CPT and

HCPCS codes allowed under the ARTS reimbursement structure. Documentation shall include

the mode of service delivery.

DMAS is waiving the requirement to use the specific telehealth billing codes in this time of

emergency.

Home as Originating Site

Prior DMAS telehealth guidance related to the prescribing of controlled substances for the

treatment of addiction delivered via telehealth required a qualified provider and a telepresenter

located at the originating site, as well as a qualified prescribing provider located at the remote site.

DMAS will allow a member’s home to serve as the originating site for prescription of

buprenorphine in accordance with the Ryan Haight Act which allows exceptions in the event of a

Public Health Emergency. This may be particularly important for members who are quarantined,

are diagnosed with and/or demonstrating symptoms of COVID-19, and/or are at high risk of

serious illness from COVID-19. Clinicians shall use clinical judgment when determining the

appropriate use of home as the originating site. The originating site fee will not be available. (This

does not apply for prescribing the initial dose of a controlled substance. Providers must follow the

DEA requirements noted above for the initial visit.) For providers who are treating members in

the home, contingency plans and emergency procedures shall be developed and documented.

In-Network Buprenorphine Waivered Practitioners

Information contained in this section for MAT applies to in-network buprenorphine waivered

practitioners. Please note that if providers are not approved as Preferred OBOT providers, care

coordination is not a reimbursable service.

If you have additional questions about the SUD-specific portions of this memo, you may also email

[email protected] in addition to the centralized access point for questions highlighted at

the beginning of this memo.

Eligibility and Enrollment Several changes are being made to Eligibility and Enrollment policies and procedures to ensure

continued coverage during this emergency. The agency’s priority is to ensure continued coverage

and access to coverage during this time. DMAS encourages uninsured patients to apply online

(www.commonhelp.virginia.gov) as the fastest way to apply for care during an emergency.

However, if patients experience interruptions in coverage or need corrections to their coverage

during this time, please contact the centralized contact option highlighted at the beginning of this

memo.

Fair Hearings and Appeals

Client Appeals

DMAS is making the following changes:

http://www.dmas.virginia.gov/files/links/310/ARTS%20Reimbursement%20Structure%20(09.18.2019).pdf

http://www.dmas.virginia.gov/files/links/5104/MSR%202019-295-001-W%20Attachment%20-%20Telemedicine%20Requirements%20for%20MAT%20OUD%20Bulletin%20V1.0%20dtd%20102319.pdf

mailto:[email protected]

http://www.commonhelp.virginia.gov/


March 19, 2020

DMAS is seeking federal authority to accept client/member appeals filed during the

COVID-19 emergency that miss the normal filing deadlines, and, if the authority is

granted, those appeals will move forward as if the deadlines were met.

For all appeals filed during the state of emergency, Medicaid members will

automatically keep their health coverage and have access to Medicaid-covered

medical services without any financial impact while the appeal is

proceeding. Medicaid managed health plans will also approve continued coverage

while their internal appeal process is underway.

All DMAS State Fair Hearings will be conducted by telephone.

DMAS will grant requests to reschedule hearings.

Appeals may be submitted to DMAS via e-mail at [email protected]

Additionally, State Fair Hearing decisions may not be issued within the normal timeframe,

depending on the length of the emergency.

Provider Appeals

Pursuant to the Governor’s Declaration of a State of Emergency issued on March 12, 2020

(Executive Order 51), the DMAS Director is authorized to waive state requirements and

regulations. DMAS is exercising this authority for deadlines that govern provider appeals that are

specified in the Code of Virginia and DMAS’ provider appeal regulations. The following changes

are being made:

Providers affected by the COVID-19 emergency can request a hardship exemption

to the normal deadline to file an appeal. The provider’s request for an informal

appeal or formal appeal must state an exemption is being requested and the reason

for the exemption.

Appeals may be submitted to DMAS via e-mail at [email protected]

All deadlines after an appeal has been filed are extended for the period of the

declaration of emergency. This applies to the following informal appeal deadlines:

case summary, informal-fact-finding conference (IFFC), document submission

after the IFFC, and the informal appeal decision. This also applies to the following

formal appeal deadlines: documentary evidence, hearing date, post-hearing briefs,

recommended decision, exceptions, and the Final Agency Decision. For example,

if the declaration of emergency lasts 50 days, these deadlines are extended 50 days.

All informal fact-finding conferences and formal hearings will be conducted by

telephone during the period of emergency.

Attachment A (Page 17): Table of Codes for Telehealth

Attachment B (Page 18): Service Authorizations Extensions or Waivers

*************************************************************************************

Medicaid Expansion Eligibility Verification

Medicaid coverage for the new expansion adult group began January 1, 2019. Providers may use the

Virginia Medicaid Web Portal and the Medicall audio response systems, as shown in the table below, to

verify Medicaid eligibility and managed care enrollment, including for the new adult group. In the Virginia

Medicaid Web Portal, individuals eligible in the Medicaid expansion covered group are shown as

“MEDICAID EXP.” If the individual is enrolled in managed care, the “MEDICAID EXP” segment will




March 19, 2020

be shown as well as the “MED4” (Medallion 4.0) or “CCCP” (CCC Plus) managed care enrollment

segment. Eligibility and managed care enrollment information is also available through the DMAS

Medicall eligibility verification system. Additional Medicaid expansion resources for providers are

available on the DMAS Medicaid Expansion webpage at: http://www.dmas.virginia.gov/#/medex.

PROVIDER CONTACT INFORMATION & RESOURCES

Virginia Medicaid Web Portal Automated

Response System (ARS) Member eligibility, claims status, payment status,

service limits, service authorization status, and

remittance advice.

www.virginiamedicaid.dmas.virginia.gov

Medicall (Audio Response System)

Member eligibility, claims status, payment status,

service limits, service authorization status, and

remittance advice.

1-800-884-9730 or 1-800-772-9996

KEPRO

Service authorization information for fee-for-

service members.

https://providerportal.kepro.com

Managed Care Programs

Medallion 4.0, Commonwealth Coordinated Care Plus (CCC Plus), and the Program of All-Inclusive

Care for the Elderly (PACE). In order to be reimbursed for services provided to a managed care enrolled

individual, providers must follow their respective contract with the managed care plan/PACE

provider. The managed care plan may utilize different guidelines than those described for Medicaid fee-

for-service individuals.

Medallion 4.0 Managed Care Program http://www.dmas.virginia.gov/#/med4

CCC Plus Managed Care Program http://www.dmas.virginia.gov/#/cccplus

PACE Program http://www.dmas.virginia.gov/#/longtermprograms

Magellan Behavioral Health

Behavioral Health Services Administrator, check

eligibility, claim status, service limits, and service

authorizations for fee-for-service members.

www.MagellanHealth.com/Provider

For credentialing and behavioral health service

information, visit:

www.magellanofvirginia.com, email:

[email protected],or

call: 1-800-424-4046

Provider HELPLINE

Monday–Friday 8:00 a.m.-5:00 p.m. For provider

use only, have Medicaid Provider ID Number

available.

1-804-786-6273

1-800-552-8627

Aetna Better Health of Virginia

aetnabetterhealth.com/virginia

1-800-279-1878

Anthem HealthKeepers Plus

www.anthem.com/vamedicaid

1-800-901-0020

Magellan Complete Care of Virginia

www.MCCofVA.com

1-800-424-4518 (TTY 711) or 1-800-643-2273

Optima Family Care 1-800-881-2166

United Healthcare Uhccommunityplan.com/VA and

myuhc.com/communityplan

http://www.dmas.virginia.gov/#/medex

http://www.virginiamedicaid.dmas.virginia.gov/

https://providerportal.kepro.com/

http://www.dmas.virginia.gov/#/med4

http://www.dmas.virginia.gov/#/cccplus

http://www.dmas.virginia.gov/#/longtermprograms

http://www.magellanhealth.com/Provider

https://www.magellanofvirginia.com/

mailto:[email protected],or

http://www.anthem.com/vamedicaid


March 19, 2020

1-844-752-9434, TTY 711

Virginia Premier 1-800-727-7536 (TTY: 711),


March 19, 2020

Attachment A

Table of Codes for Telehealth.

CODE DEFINITION Provider

Type/Specialty

99201

–

99205

99211-

99215

Initial and subsequent E&M

office visit or other outpatient

visit

MD: 020/000

NP: 023/000

FQHC: 052/000

RHC: 053/000

Health Dept.:

051/000

99221-

99223

99231-

99233

Initial and subsequent hospital

care

MD: 020/000

NP: 023/000

FQHC: 052/000

RHC: 053/000

Health Dept.:

051/000

Q3014 Telemedicine Facility Fee MD: 020/000

NP: 023/000

FQHC: 052/000

RHC: 053/000

Health Dept.:

051/000

99304-

99306

99307-

99310

Initial and subsequent physician

nursing home care

MD: 020/000

NP: 023/000

FQHC: 052/000

RHC: 053/000

Health Dept.:

051/000

99354-

99355

99356-

99357

Prolonged service office

Prolonged service inpatient

MD: 020/000

NP: 023/000

FQHC: 052/000

RHC: 053/000

Health Dept.:

051/000


March 19, 2020

ATTACHMENT B

Service Authorizations Extensions or Waivers for the Following Services:

CCC Plus, EPSDT, and DD Waiver

CCC Plus and EPSDT Services-Extend SA for 60 days HCPCS

Code Mod Description

T1019 Agency directed personal care

S5126 Consumer directed personal care

T1005 Agency respite

S5150 Consumer directed respite

S9125 TE Skilled respite

S5160 PERS installation

H2021 PERS nursing

S5161 PERS monitoring

S5185 PERS medication monitoring

S9123 EPSDT Private Duty Nursing-RN

S9124 EPSDT Private Duty Nursing-LPN

G0493 EPSDT Private Duty Nursing-Congregate-RN

G0494 EPSDT Private Duty Nursing-Congregate-LPN

DD Waiver Services-Extend SA for 60 days

HCPCS Code

Mod Description

T1019 Agency directed personal care

S5126 Consumer directed personal care

T1005 Agency respite

S5150 Consumer directed respite

S5135 Agency Companion

S5136 Consumer directed Companion

T2032 U1 Independent Living

H0043 Supported Living

H2014 U1 In Home Supports Tier 1



H2022 UA Group Home Tiered

H2022 U2 Group Home Tiered








March 19, 2020


T2033 Sponsored Residential

Scans

Waive SA for 60 days CPT Code

Mod Description

71250 COMPUTED TOMOGRAPHY, THORAX; WITHOU

71260 COMPUTED TOMOGRAPHY, THORAX; WITH C

71270 CT THORAX W/O & W/DYE

71275 CT ANGIOGRAPHY CHEST

Service Authorization Waived for Home Health:

0550 Skilled Nursing Assessment

0551 Skilled Nursing Care, Follow-Up Care

0559 Skilled Nursing Care, Comprehensive Visit

0571 Home Health Aide Visit

0424 Physical Therapy, Home Health Assessment

0421 Physical Therapy, Home Health Follow-UP Visit

0434 Occupational Therapy, Home Health Assessment

0431 Occupational Therapy, Home Health Follow-Up Visit

0444 Speech-Language Services, Home Health Assessment

0441 Speech Language Services, Home Health Follow-Up Visit

0542 Non-Emergency Transportation, Per Mile

Durable Medical Equipment:

HCPCS Code

Description

Respiratory

E0618 Apnea Monitor without recording feature

E0619 Apnea Monitor with recording feature

A4604 Tubing with integrated heating element for use with positive airway pressure device

A4608 Transtracheal oxygen catheter, each

A7025 High Frequency chest wall oscillation system vest, replacement for with patient owned equipment, each

A7026 High Frequency chest wall oscillation system hose, replacement for use with patient owned equipment, each

A7044 Oral interface used with positive airway pressure device, each


March 19, 2020

E0430 Portable Gaseous Oxygen System, purchase, Includes Regulator, flowmeter, humidifier, cannula or mask, and tubing

E0433 RR Portable liquid liquid oxygen system, rental; home liquefier used to fill portable liquid oxygen containers, includes portable containers, regulator, flowmeter, humidifier, cannula or mask and tubing, with or without supply reservoir and gauge

E0435 Portable liquid oxygen system, purchase, includes portable container, supply reservoir, flowmeter, humidifier, contents gauge, cannula or mask, tubing, and refill adapter

E0441 Stationary oxygen contents, gaseous, 1 month supply = 1 unit

E0444 Portable oxygen contents, liquid, one month's supply = 1 unit

E0447 Portable oxygen contents, liquid, one month's supply = 1 unit, prescribed amount at rest or nighttime exceeds 4 liters per minute (lpm)

E0445 Oximeter device for measuring blood oxygen levels, non-invasively

E0445 RR Oximeter device for measuring blood oxygen levels, non-invasively

E0465 Home ventilator, any type, used with invasive interface, (e.g., tracheostomy tube)

E0465 RR Home ventilator, any type, used with invasive interface, (e.g., tracheostomy tube)

E0466 Home ventilator, any type, used with non-invasive interface, (e.g., mask, chest shell)

E0466 RR Home ventilator, any type, used with non-invasive interface, (e.g., mask, chest shell)

E0467 Home Ventilator, multi-function respiratory device, also performs any or all of the additional functions of oxygen concentration, drug nebulization, aspiration, and cough stimulation, includes all accessories, components and supplies for all functions

E0467 Home Ventilator, multi-function respiratory device, also performs any or all of the additional functions of oxygen concentration, drug nebulization, aspiration, and cough stimulation, includes all accessories, components and supplies for all functions

E0457 Chest shell (cuirass)

E0457 RR Chest shell (cuirass)

E0460 Negative pressure ventilator, portable or stationary

E0461 RR Volume ventilator, stationary or portable, with backup rate feature, used with non-invasive interface

E0470 Respiratory Assist Device, bi-level pressure capability, w/out backup rate feature, used w/noninvasive interface e.g. nasal or facial mask.


March 19, 2020

E0470 RR Respiratory Assist Device, bi-level pressure capability, w/out backup rate feature, used w/noninvasive interface e.g. nasal or facial mask.

E0471 Respiratory assist device, bi-level pressure capability, w/backup rate feature, used w/noninvasive interface, eg. Nasal or facial mask

E0471 RR Respiratory assist device, bi-level pressure capability, w/backup rate feature, used w/noninvasive interface, eg. Nasal or facial mask

E0472 Respiratory Assist Device, bi-level pressure capability, with backup rate feature, used with invasive interface, e.g. tracheostomy tube (intermittent assist device with continuous positive airway pressure device)

E0472 RR Respiratory Assist Device, bi-level pressure capability, with backup rate feature, used with invasive interface, e.g. tracheostomy tube (intermittent assist device with continuous positive airway pressure device)

E0480 Percussor, Electric Or Pneumatic, Home Model

E0480 RR Percussor, Electric Or Pneumatic, Home Model

E0482 Cough stimulating device

E0482 RR Cough stimulating device

E0483 High frequency chest wall oscillation system, includes all accessories and supplies, each

E0483 RR High frequency chest wall oscillation system, includes all accessories and supplies, each

E0500 IPPB Machine, all types, w/built-in nebulization; manual or automatic valves; internal or external power source

E0500 RR IPPB Machine, all types, w/built-in nebulization; manual or automatic valves; internal or external power source

E0565 Compressor, air power source for equipment which is not self contained or cylinder driven

E0565 RR Compressor, air power source for equipment which is not self contained or cylinder driven

E0575 Nebulizer, Ultra-Sonic large volume

E0575 RR Nebulizer, Ultra-Sonic large volume

E0601 Continuous Positive Airway Pressure (CPAP) Device

E0601 RR Continuous Positive Airway Pressure (CPAP) Device

E1352 Oxygen accessory, flow regulator capable of positive inspiratory pressure

E1353 Regulator

E1355 Stand/Rack


March 19, 2020

E1372 Immersion external heater for nebulizer

E1372 RR Immersion Heater For Nebulizer

S8120 Oxygen contents, gaseous, 1 unit equals 1 cubic foot

S8121 Oxygen contents, liquid, 1 unit equals 1 pound

S8999 Resuscitation bag (for use by patient on artificial respiration during power failure or other catastrophic event)

Diabetic supplies

S5560 Insulin delivery device, reusable pen, 1.5 ml size

S5561 Insulin delivery device, reusable pen, 3 ml size

Enteral Nutrition

B9002 Enteral Nutrition Infusion Pump, Any Type

B9004 Parenteral nutrition unfusion pump, portable

B9006 Parenteral nutrition unfusion pump, stationary

E0791 Parenteral infusion pump, stationary, single or multichannel

Blood pressure

A4670 Automatic Blood Pressure Monitor

Ostomy supplies

A4387 Ostomy pouch, closed, with barrier attached, with built in convexity (one piece), each

A5120 Skin Barrier Wipes or swabs, each

richmond, virginia 23219

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